PRIVACY POLICY
Cincinnati Global is responsible for the management of Syndicate 318 Underwriters at Lloyd’s
Introduction
Welcome to Cincinnati Global’s privacy policy.
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
The persons to which this Privacy Policy applies
This privacy policy applies to individuals (“you”) whose personal data we collect in relation to the quotation, sale and administration of our insurance products by all channels and includes claims. This includes actual and potential policyholders, suppliers, brokers, advisers, service providers (including expert witnesses and expert service providers), beneficiaries and their representatives and third party claimants and their representatives.
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through:
(a) your use of this website including any data you may provide through this website when you make an enquiry about a product or service; and/or
(b) any interaction between you and a member of Cincinnati Global through any other sales, service or claims channels, including where your personal data is provided to us by your broker or other third party.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
We would also recommend that you read the Lloyd’s Market Association’s Insurance Market Core Uses Information Notice (available at https://londonmarketgroup.co.uk/gdpr). This is an insurance market standard information notice which explains in more detail how the insurance market works and uses personal data to provide insurance cover, particularly in relation to the Lloyd’s Market Association where multiple organisations can be involved in the underwriting and administration of insurance products.
This privacy policy supplements other notices and privacy policies and is not intended to override them.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
Cincinnati Global Underwriting Ltd. operates through Cincinnati Global Underwriting Agency Ltd., which is the Lloyd’s managing agent for Cincinnati Global Syndicate 318. Details of these legal entities can be found here. Collectively, the group is known as Cincinnati Global. This privacy policy is issued on behalf of Cincinnati Global so when we mention “we”, “us” or “our” in this privacy policy, we are referring to the relevant company within Cincinnati Global responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.
We have appointed a Data Protection Officer (DPO) within our Compliance team who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights , please contact the DPO using the details set out below.
Contact Details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Cincinnati Global Underwriting Agency Ltd.
Email address: compliance@cinfinglobal.com
Postal address: 1 Minster Court, Mincing Lane, London, EC3R 7AA, for the attention of the Data Protection Officer
Telephone number: +44(0)20 7220 8200
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 11.07.2022, It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The personal data we collect may vary across our product range. If you are a Cincinnati Global policyholder or a prospective policyholder (please note that if you are a contact at a corporate Cincinnati Global policyholder the Thirds Parties section will apply to you instead), or if you are the beneficiary of a Cincinnati Global policy, please see below for more information about the personal data we collect in relation to each product. Please note that we do not process your personal data in relation to our Credit and Political Risk Insurance or War, Terrorism and Political Violence Insurance products.
If you are not a Cincinnati Global policyholder (or prospective policyholder) or beneficiary, please click on the Third Parties section for information about how we use your personal data.
Types of personal data we may collect:
- Identity Data includes first name, middle name(s), last name, marital status, title, date of birth and gender.
- Contact Data includes the address of the insured property if applicable, your postal address, email address and telephone numbers.
- Profile Data includes information about your enquiries and/or purchases, the risk insured or to be insured, claims, interests, preferences and feedback.
- Usage Data includes information about how you use our products and services.
- Health Data includes information about your health including known medical conditions and/or injuries sustained in relation to an insured incident. We only collect Health Data in relation to our Contingency and Film & Entertainment Insurance Products
Third Parties
In the course of conducting our insurance business, we expect to collect and process personal data relating to the following categories of individuals whom we refer to in this privacy policy as Third Parties:
– Contacts at corporate insurance clients
– Third party claimants under a Cincinnati Global policy which offers third party liability cover;
– Witnesses to an insured incident;
– Individuals who have caused Cincinnati Global policyholder a loss;
– Legal representatives, legal advisers and claims handlers;
– Medical professionals;
– Expert witnesses or other expert service providers; and
– Brokers and appointed representatives; and
- Identity Data includes first name, middle name(s), last name, marital status, title, date of birth and gender.
- Contact Data includes your residential address or work postal address, email address and telephone numbers.
- Health Data includes information about your health including injuries sustained in relation to an insured incident.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. As stated in this article, you can browse your selection of available deals on smartphones and top brands and explore the service plans that best suit your needs.
We do not use cookies or collect any data about you or your device when you visit our website.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with insurance cover). In this case, we may have to cancel a product or policy you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You (either directly or via your broker) may give us your Identity Data, Contact Data and, where applicable, Health Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
– enquire about, apply for and/or purchase our products or services;
– make a claim against a policy; or
– complain, give us feedback or generally contact us.
- Indirect interactions. We may receive your Identity Data, Contact Data and, where applicable, Health Data from our policyholders where you are a beneficiary under a product or a family member of such a beneficiary or we may receive such information from your representatives (including legal representatives or insurer) where you are a third party claimant.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
– Health Data from medical professionals.
– Identity and Contact Data from insurance agents and brokers.
– Identity and Contact Data from financial crime or fraud agencies, databases and sanctions lists.
– Identity and Contact Data from credit reference agencies.
– Identity and Contact Data from third parties who provide us with services relating to your product or services including loss adjusters, legal advisers, assistance providers, experts and, in some limited circumstances, private investigators.
– Identity, Contact and Financial Data from third parties who provide us with data accuracy services.
– Identity and Contact Data from insurance industry bodies.
– Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you or take steps at your request before entering into such a contract with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
We have set out in a table format for each product a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in any relevant table.
If you are not a Cincinnati Global policyholder or prospective policyholder or beneficiary, or you are a contact at a corporate Cincinnati Global policyholder, please click on the Third Parties section for information about how we use your personal data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer | Identity Contact | Performance of a contract with you |
| To arrange, underwrite (including assessing insurance risk) or manage your policy including handling claims in accordance with your policy terms and conditions and financial services regulatory requirements | Identity Contact Profile Health (for Contingency and Film & Entertainment Insurance products only) | Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to determine whether to offer cover and the terms of such cover) |
| To manage our relationship with you which will include: Notifying you about changes to your insurance policy’s terms and conditions or this privacy policy Handling complaints made by you | Identity Contact Profile Usage Technical | Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated) |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
| To use data analytics to improve our products/services, marketing, customer relationships and experiences | Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To recover losses from at-fault third parties | Identity Health (for Contingency and Film & Entertainment Insurance products only) | Necessary for our legitimate interests (to safeguard our business and to enforce our legal rights) |
| To manage relationships with brokers and third parties in the insurance sector in relation to your policy | Identity Contact Profile | Necessary for our legitimate interests (to provide you with the best possible service) |
| To carry out anti-fraud and anti-money laundering checks and other due diligence activity | Identity Contact | Necessary to fulfil a legal obligation In the public interest |
| To enable the detection and prevention of unlawful acts | Identity Contact Profile | In the public interest |
| To fulfil regulatory requirements | Identity Contact Profile | Necessary to fulfil a legal obligation |
Third Parties
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To work with you to arrange, underwrite, administer and manage insurance policies | Identity Contact | Necessary for our legitimate interests (to grow and manage our business and serve our customers) |
| To manage our relationship with you which will include: Notifying you about changes to your (or, if you are a broker, your customer’s) policy terms and conditions or this privacy policy | Identity Contact | Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated) |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
| To use data analytics to improve our products/services, marketing, customer relationships and experiences | Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To recover losses which we have paid to our policyholder | Identity Contact | Necessary for our legitimate interests (to safeguard our business and to enforce our legal rights) |
| To engage you to provide us with services | Identity Contact | Performance of a contract with you |
| To arrange payment of sums due to you | Identity Contact | Performance of a contract with you or a third party whom you represent |
| To investigate and handle claims made by you or on your behalf where our policyholder has caused you a loss | Identity Contact Health (where a Cincinnati Global policy covers relevant third party liability | Performance of a contract with our policyholder Necessary for our legitimate interests (to exercise our legal rights or defend claims) Necessary to fulfil a legal obligation |
| To obtain witness statements and other relevant information from you in relation to an insured incident | Identity Contact | Necessary for our legitimate interests (to exercise our legal rights or defend claims) |
| To carry out anti-fraud and anti-money laundering checks and other due diligence activity | Identity Contact | Necessary to fulfil a legal obligation In the public interest |
| To enable the detection and prevention of unlawful acts | Identity Contact Profile | In the public interest |
| To fulfil regulatory requirements | Identity Contact Profile | Necessary to fulfil a legal obligation |
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and reinsurers who provide consultancy, banking, legal, insurance and accounting services.
- Insurance agents and brokers
- Financial advisors acting for you
- HM Revenue & Customs, regulators and other authorities.
- Anti-fraud, anti-money laundering and law enforcement bodies, including the police.
- Civil and criminal courts
- Industry bodies and other members of the insurance industry involved in the provision of your insurance cover, including brokers, loss adjusters and insurance administrators
- Medical professionals for the provision of medical reports or access to health records.
- Third party insurers
- Credit reference agencies, to analyse credit risk
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within the Cincinnati Global and with third parties based outside the UK who provide us with services. This will involve transferring your data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our DPO.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.